G.R. No. L-43060 June 22, 1978
ROBERTO VALENCIA, petitioner, vs. REPUBLIC OF THE PHILIPPINES (Bureau of Telecommunications) and the WORKMEN’S COMPENSATION COMMISSION, respondents.

FACTS

Petitioner Roberto Valencia was employed as a telephone lineman by the Bureau of Telecommunications starting November 26, 1945. His duties involved repairing broken telephone lines, which often required him to work during emergencies and take belated meals. In December 1968, he manifested symptoms of gastric ulcer, including frequent pains and bloody stools, and was diagnosed by his attending physician, Dr. Godofredo V. Faller. He filed a claim for disability benefits and medical reimbursement on March 24, 1975. The Acting Referee granted his claim, awarding compensation and medical expenses.
The respondent Bureau appealed to the Workmen’s Compensation Commission, which reversed the Referee’s decision and disallowed the claim. The Commission ruled that the gastric ulcer was not work-connected but was due to “hyperacidosis of the gastric content and the dietary habits of the claimant.” It also held that Valencia’s retirement under the Optional Retirement Law indicated he did not retire due to work-related incapacity.

ISSUE

Whether petitioner’s gastric ulcer is compensable as a work-related illness under the Workmen’s Compensation Act.

RULING

Yes. The Supreme Court reversed the Commission’s decision and reinstated the award with modifications. The legal logic is anchored on the presumption of compensability and the substantial evidence presented. Under the Workmen’s Compensation Act, when an illness supervenes during employment, as Valencia’s did after 23 years of service, it is presumed to have arisen out of or been aggravated by such employment. The burden to rebut this presumption shifts to the employer, which the respondent Bureau failed to do.
The Court found the Commission erred by isolating the physician’s answer regarding “hyperacidosis and dietary habits” from the full context of the medical report. The same report explicitly stated, in response to subsequent queries, that the illness was partially caused and aggravated by the nature of his employment, which required outdoor repair work and led to irregular meals. The Court reasoned that hyperacidity, the direct cause of ulcer, can be precipitated by irregular eating habits fostered by the exigencies of one’s job. It is sufficient that the employment contributed, even in a small degree, to the development of the disease; the claimant need not prove causation to a point of absolute certainty.
Furthermore, retirement under the Optional Retirement Law is not a bar to compensation. The law itself allows optional retirement for employees physically incapacitated to render efficient service. Therefore, such retirement does not equate to a voluntary stoppage of work but can be consistent with work-related disability. The Court consistently allows compensation claims even when claimants avail of optional retirement, provided the illness is work-connected.